Ms Cora O'Brien:

It is far from clear what will happen at the end of the BEPS process. There are hugely varying views and countries have very different concerns. As Professor Stewart has stated, there are countries with big consumer markets and they believe they need more because they have more consumers. It is not clear, when the BEPS process is complete, whether issues around tax that is attributable to consumer markets will be dealt with through indirect taxes and VAT and whether that is the right way to deal with consumer taxes. As for the issue of where value is added, where products are developed, where research and development takes place and whether that will be the right basis for corporation tax, it is unclear as to where that debate will end up. There are arguments both ways but there is a big school of thought to the effect that corporation tax based on consumer markets is not the right basis for that particular type of tax.